Virtual Countries, Inc. v. Republic of South Africa, a Foreign State, and South African Tourism Board, an Agency or Instrumentality of a Foreign State

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that there was no direct effect where the alleged injury would not have occurred but for the actions of various third parties
• finding no direct effect because “[n]o obligation—contractual or otherwise—ran to the plaintiff from the [defendant], let alone one to be performed in the United States”
• observing speculative injuries do not suffice to satisfy 28 U.S.C. § 1605(a)(2)’s third clause
• the “theoryf ] that any ‘U.S. corporation’s financial loss constitute^] a direct effect in the United States[ ]’ ... is plainly flawed” (emphasis in original)
• “[M]ere financial loss without a legally significant act does not establish jurisdiction.” (quotation marks and citation omitted)
• “No obligation—contractual or otherwise—ran to the plaintiff from the Republic, let alone one to be performed in the United States.”

Source: CourtListener parenthetical corpus (CC0).